by Greg Toppo, USA TODAY

by Greg Toppo, USA TODAY

District of Columbia Public Schools officials have long maintained that a 2011 test-cheating scandal that generated two government probes was limited to one elementary school. But a newly uncovered confidential memo warns as far back as January 2009 that educator cheating on 2008 standardized tests could have been widespread, with 191 teachers in 70 schools "implicated in possible testing infractions."

The 2009 memo was written by an outside analyst, Fay "Sandy" Sanford, who had been invited by then-chancellor Michelle Rhee to examine students' irregular math and reading score gains. It was sent to Rhee's top deputy for accountability.

The memo notes that nearly all of the teachers at one Washington elementary school had students whose test papers showed high numbers of wrong-to-right erasures and asks, "Could a separate person have been responsible?"

It recommends that DCPS contact its legal department "as soon as you think it advisable" and ask them to determine "what possible actions can be taken against identified offenders."

DCPS officials have said they take all cheating allegations seriously, but it's not immediately clear how they responded to Sanford's warnings. Only one educator lost his job because of cheating, according to DCPS. Meanwhile, Rhee fired more than 600 teachers for low test scores - 241 of them in one day in 2010.

The cheating issue first came to light in 2011, after USA TODAY reported that, between 2008 and 2010, 103 schools had test-erasure rates that surpassed districtwide erasure-rate averages at least once.

Erasures are detected by the same electronic scanners used to score tests. When a teacher or student erases a bubble sheet, this leaves behind a light smudge. Computers tally the smudges as well as the new answers.

The USA TODAY investigation found that, as far back as 2008, the Office of the State Superintendent of Education (OSSE), D.C.'s equivalent of a state education department, asked for an erasure analysis. Among the 96 schools flagged for wrong-to-right erasures were eight of the 10 campuses where Rhee handed out so-called TEAM awards "to recognize, reward and retain high-performing educators and support staff." In all, Rhee bestowed more than $1.5 million in bonuses based on increases in 2007 and 2008 test scores.

The USA TODAY investigation led to inquiries by the D.C. Office of the Inspector General and the U.S. Department of Education's Inspector General. Neither found evidence of widespread cheating, but both primarily focused on just a handful of schools.

The 2009 memo was obtained by veteran education journalist John Merrow, who has been covering Rhee since her arrival in D.C. in 2007. His documentary on her legacy ran on PBS' Frontline in January.

Merrow provided a copy of the memo to USA TODAY on Thursday. Its findings stand in stark contrast to public statements made both by Rhee and her onetime deputy, Kaya Henderson, now D.C.'s chancellor. In a Jan. 8 statement coinciding with Merrow's broadcast, Henderson noted, "All of the investigations have concluded in the same way that there is no widespread cheating at D.C. Public Schools." She added, "We take test security incredibly seriously and will continue to do so even after our name has been cleared."

Sanford's memo warns its intended recipients to "keep this erasure study really close (sic) hold. No more people in the know than necessary until we have more conclusive results."

The memo suggests, "Don't make hard copies and leave them around. Much of what we think we know is based on what I consider to be incomplete information. So the picture is not perfectly clear yet, but the possible ramifications are serious."

At the time, many D.C. schools, as well as those nationwide, were struggling to meet the federal government's "adequate yearly progress" (AYP) levels, which required year-to-year test score gains. Agencies such as OSSE were pushing for improvements.

"If all 70 schools wind up being compromised AND OSSE wants AYP blood," the memo warns, "the result could be devastating with regard to our reported gains in 2008."

In a statement, Rhee said she didn't recall getting Sanford's memo: "As chancellor I received countless reports, memoranda and presentations. I don't recall receiving a report by Sandy Sanford regarding erasure data from the (DC Comprehensive Assessment System), but I'm pleased, as has been previously reported, that both inspectors general (DOE and DCPS) reviewed the memo and confirmed my belief that there was no widespread cheating."

Henderson's spokeswoman, Melissa Salmanowitz, said the chancellor "has no recollection of receiving/reading this document, nor of discussing it with then-chancellor Rhee" because Henderson wasn't involved in erasure analysis at the time. But Salmanowitz said DCPS' testing company noted that the district didn't have enough information to conduct an investigation and, based on Sanford's analysis, shouldn't necessarily conclude that cheating had occurred.